The MHA recently submitted a comment letter opposing the U.S. Department of Education’s proposed rule that would change how certain graduate health programs qualify for federal student loan programs under H.R. 1.
The proposal would revise the definition of “professional student” and “professional degree” under 34 CFR 685.102, limiting enhanced federal borrowing eligibility to certain doctoral-level programs. The MHA raised concerns that the proposal does not reflect the structure of today’s healthcare workforce and could worsen existing provider shortages.
Hospitals across Michigan rely on a range of licensed health professionals, including licensed clinical social workers, professional counselors, advanced practice nurses, registered nurses and physician assistants. Many of these providers complete accredited programs, meet clinical training requirements and obtain state licenses. However, several of these programs would not qualify as “professional” under the proposed rule.
The MHA cautioned that restricting loan eligibility for these programs could discourage students from entering fields already facing workforce shortages. Nearly all rural Michigan counties are designated as Health Professional Shortage Areas (HPSAs) for primary care and behavioral health, and many hospitals rely on master’s-level clinicians to maintain access to care.
The MHA urged the Department of Education to adopt a broader definition that reflects accreditation and licensure standards. The MHA will continue monitoring the rulemaking process and share updates with members as they become available.
Members with questions may contact Lenise Freeman at the MHA.